ADDITIONAL DISCLOSED MATERIAL

Schedule 9g

THE CONTRACT PLAN APPENDIX 12 (NSL SAFETY STATEMENT) Safety Statement

NSL Ltd Fourth Floor Westgate House Westgate London W5 1YY

www.nsl.co.uk | CONTENTS | Page No | |------------------------------------------------------------------------|---------| | Health and Safety Policy | 3 | | 1.0 Introduction | 4 | | 2.0 Applicable legislation | 5 | | 3.0 Hazards identified and risks assessed | 5 | | 4.0 Organisation | 6 | | 5.0 Consultation with employees | 7 | | 6.0 Networks and communication | 8 | | 7.0 Planning health and safety | 9 | | 8.0 Implementing health and safety | 10 | | 9.0 Safety information | 11 | | 10.0 Training and competence | 12 | | 11.0 Safety of members of the public | 12 | | 12.0 Contractors | 12 | | 13.0 Emergency procedures | 13 | | 14.0 Occupational health | 13 | | 15.0 Measuring performance | 14 | | 16.0 Review | 15 | | Appendix A Duties of Managers | 16 | | Appendix B Duties of Employees | 17 | | Appendix C Duties of the Health and Safety Manager | 18 | | Appendix D Health and Safety training | 19 | | Appendix E Health and Safety information | 20 | Health and Safety Policy Statement

April 2011

As a responsible and progressive employer, NSL recognises that people are our primary asset and as such have prepared this Health and Safety Policy Statement, in accordance with the Health and Safety at Work etc Act 1974. This statement forms part of our integrated management system and it will be prominently displayed at every location where employees are based.

The Chief Executive and Executive Board have ultimate responsibility for health and safety, and they ensure that an appropriate organisational structure is in place to maintain the required standards across all areas of the Company. The Health and Safety Manual includes detailed arrangements for achieving this, and each manager ensures that the policies and procedures within are implemented across their area of responsibility.

NSL has a pro-active approach to health and safety, with an emphasis on prevention rather than cure. The intention is to continually develop using all available information; measuring, monitoring, auditing and reviewing to improve the effectiveness of risk management techniques. The Company employs both active and re-active monitoring systems to evaluate the success of arrangements and a programme of continuous improvement is designed to promote universal ownership of all areas of health and safety.

NSL will:

- Promote a culture supportive of health and safety, facilitated by effective communication
- As a minimum standard, comply with all legislative requirements relating to health, safety and welfare
- Provide safe working environments and suitable equipment, with formal procedures for safe use
- Utilise a systematic approach to the identification of risk to anyone who may be affected by Company activities, and the implementation of appropriate measures to control them
- Seek to achieve the highest standards of health, safety and welfare as an integral part of the management of the Company, taking proper account of health and safety requirements in all business activities
- Provide a structured organisation, led by effective management and supported by competent employees, encouraging full involvement and participation by all
- Provide suitable training, instruction and supervision to maintain the safety of colleagues; with adequate means for employee consultation to ensure effective collaboration in all aspects of health and safety
- Recognise that circumstances leading to an incident may be the result of collective failings, and not necessarily the failings of an individual. Suitable investigation will be carried out, to identify the root causes of an incident, in order to prevent where possible, similar events from occurring in the future
- Develop and implement procedures and systems to prevent and / or mitigate and emergency situations

Employees’ Duties

Each colleague also has a responsibility to ensure that they;

- Take care of their own health and safety, and that of their fellow workers and visitors
- Appropriately use anything that has been provided in the interests of health and safety
- Are not involved in any unsafe acts or reckless behaviour
- Co-operate with the Company in matters of health and safety and report any concerns to their line manager without delay
- Comply with health and safety legislation, policy and procedure at all times

Successful health and safety management requires each individual to play their part, and co-operation and commitment from everyone are essential to ensure that standards are maintained. This shared expectation may be supported by the Company disciplinary procedure, if necessary.

Mark Underwood Chief Executive 1.0 Introduction

NSL aims to achieve and maintain the highest standard of health, safety and welfare for employees, employees of other organisations and members of the public who use its premises or equipment. NSL also expects the highest standards from its contractors and recognises its role in co-ordinating safety in common-user areas by setting and monitoring standards where relevant and appropriate.

NSL will comply with current health and safety legislation and the objectives of its own Health and Safety Policy. Wherever appropriate, NSL adopts best practice where this can be established by research and analysis. In the absence of specific regulations it will prepare processes and adopt safety standards based on risk assessments, to protect everyone who may be affected by its operations. Where there is no NSL process, Health and Safety Executive guidance, Codes of Practice, or other nationally accepted ‘best working practice’ will set the appropriate standard.

Through its risk assessment programmes NSL seeks to identify and, as far as is reasonably practicable, eliminate hazards or otherwise control them. By considering health and safety at the design stage of projects, NSL aims to ensure high standards of health and safety during procurement and implementation, ensuring the appropriate design and layout of premises and the correct supply of equipment, machinery, articles and substances.

The provision of sufficient funds for health and safety matters will be built into the budgets of relevant departments each year, for ongoing improvements, maintenance and repair and replacement projects as required. Where funds are required outside of this planned allocation for more immediate problems that are safety critical, then these will be so provided.

Health and safety policies are brought to the attention of all employees in a summarised Colleague Health and Safety Handbook which, is issued to every employee. This handbook sets out the various standards described in the Health and Safety Manual and is reviewed regularly with any changes in policy being immediately brought to the attention of all employees.

In the mutual interests of everyone, all employees are advised that the management of the Company may take any disciplinary action that proves to be necessary to ensure compliance with any Act, Order or Regulation introduced for health and safety reasons. The disciplinary procedures to be adopted are laid down in the Colleague Handbook of Employment.

NSL will review its policies and procedures annually and bring all updates to the attention of employees as soon as they have been completed. Copies of these policies and procedures will be permanently available on the NSL intranet ‘CASCADE’ and as a hard copy at each place of work. 2.0 Applicable legislation

NSL will comply with all applicable legislation, and in particular the Health and Safety Manual and all Company processes will take account of:

- *Health and Safety at Work etc Act 1974*
- *Management of Health and Safety at Work Regulations 1999*
- *Workplace (Health, Safety and Welfare) Regulations 1992*
- *Manual Handling Operations Regulations 1992 (as amended)*
- *Health and Safety (Display Screen Equipment) Regulations 1992*
- *Personal Protective Equipment at Work Regulations 1992 (as amended)*
- *Control of Asbestos Regulations 2006*
- *Regulatory Reform (Fire Safety) Order 2005*
- *Health and Safety (First Aid) Regulations 1981*
- *Control of Substances Hazardous to Health Regulations 2002 (as amended)*

3.0 Hazards identified and risks assessed

As required by the *Management of Health and Safety at Work Regulations*, a program to identify all hazards that are associated with the operation and to assess the risks that these present has been undertaken. Completed risk assessments are communicated to employees and are available for review at all times. In summary, the significant hazards identified during the process were:

| Operation | Hazard(s) | Risk | |--------------------|-----------------------------------------------|--------| | Enforcement | Confrontation, Slips & trips, Weather, Traffic, Lone working, Carrying equipment | Medium | | Scooter riding | Confrontation, Traffic, Weather, Riding the scooter, Lone working | Medium | | Wheel clamping | Confrontation, Traffic, Driving the clamp van, Manual handling, Safety of clamps in the van, Removing damaged clamps | Medium | | Vehicle removal | Confrontation, Traffic, Driving the removal truck, Manual handling, Fall from vehicle, Crane operation | Medium | | Pound operation | Pedestrian safety, Slips & trips, Fire, Electricity, DSE use, Confrontation / robbery | Medium | Controls to manage the risks posed by the above hazards and information describing who is responsible for their implementation are described on the individual risk assessment documents. As described in full in Section 7 of the Health and Safety Manual, risk assessments will be reviewed at least every 12 months or sooner if there is a significant change in circumstances, and the updated finding communicated to employees at the same time.

4.0 Organisation

4.1 Directors and Executive Board members

4.1.1 Chief Executive The Chief Executive has overall responsibility for all health and safety matters, including the setting of policy, and will ensure that adequate resources are available to meet all requirements, so far as is reasonably practicable, and that all employees under his control are aware of their own responsibilities and duties in relation to health and safety.

4.1.2 Operations Director The Operations Director has executive responsibility for the fulfilment of statutory duties under the Health and Safety at Work etc Act 1974 and is responsible to the Chief Executive for ensuring that the Company’s Health and Safety Policy is applied effectively.

4.2 Managers The various duties and responsibilities regarding health and safety will be delegated through Heads of Department and General Managers, and shared by all managers who are accountable for the health and safety of their employees and members of the public in areas under their control. They must take all reasonable precautions to prevent work related illness, accidents or dangerous occurrences within their areas. The health and safety duties of managers are given in Appendix A.

4.3 Employees In accordance with their conditions of employment and health and safety legislation, employees are required to be aware of and comply with relevant instructions and codes of safe practice in order to maintain safe and healthy places of work. Employees must act responsibly to do everything to prevent injury or illness to themselves and others and are expected to actively support and promote health and safety at work. The health and safety duties of employees are given in Appendix B.

4.4 Health and Safety Manager The Health and Safety Manager reports to the Head of Professional Standards and is responsible for co-ordinating, advising on policy development and monitoring health and safety to ensure that NSL complies with its Health and Safety Policy and discharges its duty under the Health and Safety at Work etc Act 1974 and other legislation. In particular he provides detailed safety standards, policies, procedures and processes to interpret and implement relevant legislation.

The duties of the Health and Safety Manager are given in Appendix C and although he reports to the Head of Professional Standards, the Health and Safety Manager has direct access to the Chief Executive when necessary.

The Health and Safety Manager is available for consultation at all times on specific health and safety matters and has access to other external professional sources for health and safety advice and information. These range from groups such as the Health and Safety Executive and the Institution of Occupational Safety and Health (IOSH), to external solicitors and consultants.

### 4.5 Health and safety structure and responsibilities

| Title | Name | Role / responsibilities | |------------------------|-----------------|-----------------------------------------------------------------------------------------| | Chief Executive | Mark Underwood | Overall responsibility for the organisation, implementation, resourcing and management of health and safety within NSL | | Operations Director | Alastair Cooper | Responsible for the organisation, management and communication of health and safety within NSL | | Health and Safety Manager | Mark Tucker | Responsible for co-ordinating, advising on policy development and monitoring health and safety to ensure that NSL complies with legislation. | | General Manager | Michael Adewole | Responsible for the integration of health and safety management into all management functions | | Regional Manager | Neil Hutchins | Responsible for the effective management of health and safety within the region | | Contract Manager | | Responsible for the implementation and management of health and safety policies within their operation | | Team Leaders | | Responsible for setting a good example regarding health and safety standards to staff under their control, providing advice and guidance and identifying any training needs | | Safety Representatives | | Regularly seek from employees they represent any health and safety issues that affect them and report to management any issues that have been brought to their attention | | All Employees | | Comply with relevant laws and protect their own safety and health, as that of anyone who may be affected by their acts or omissions at work. |

### 5.0 Consultation with employees

NSL will consult with employees and / or Safety Representatives with regard to safety, health and welfare at work and will provide all relevant information on these matters. Consultation may take many forms, and specifically the company will;

- Consult with employees and / or their safety representative(s) on any proposed measures likely to substantially affect their safety, health or welfare at work.

- Provide employees and / or their safety representative(s) with the results of the risk assessment and consult with them on the preparation of policies and procedures.

- Provide employees and / or their safety representative(s) with other relevant information, including details of any reportable accidents, illnesses or dangerous occurrences, the names of any competent persons appointed to advise on safety and health matters and the preventative and protective measures to be taken to avoid risks. Direct consultation with employees will also take place at Employee Consultation Committee (ECC) meetings and everyone has the opportunity to communicate direct with management using an Employee Response Form, as described in the Health and Safety Manual.

Employees may decide to elect a Safety Representative from within the workforce. This process will be actively supported and facilitated by NSL contract management. Safety Representative(s) will;

- Regularly seek from the employees they represent, any health and safety issues that affect them, including information about the issues and any suggestions for control of the issues.
- Report to management any health and safety issues that they have become aware of from their own experiences or that have been brought to their attention by employees, and assist management in determining appropriate solutions.
- Be informed immediately when an Inspector of the Health and Safety Executive (HSE) visits the premises and may accompany the Inspector during his/her visit.
- Have the opportunity to carry out inspections on the premises (subject to prior arrangement with management).
- Investigate complaints made by employees (after giving reasonable notice to management).
- Investigate accidents and dangerous occurrences independently of management or the HSE, but without disturbing the accident situation and circumstances, if they so decide.
- Have the right to such information from management as is necessary to ensure, so far is reasonably practicable, the safety and health of employees at work.
- Receive advice and information from the HSE on matters of health and safety at work and assist in keeping fellow employees fully informed of developments on any relevant issues.
- Be given time off from work, without loss of remuneration, to receive appropriate training.
- Not be placed at any disadvantage in relation to their employment as a result of the discharge of their duties as a Safety Representative.

6.0 Networks and communication

Information Regular meetings take place between operational management and the Health and Safety Manager to exchange information and discuss systems to develop ‘best practice’. Contacts are also maintained with the enforcing authorities, other appropriate groups and safety professionals.

Operations Meetings The Operations Director holds monthly meetings with the senior operational managers. At all of these meetings Health and Safety is on the agenda. This is replicated in operational meetings, at all levels across the organisation. At each of these meetings there is a dedicated session relating to Health and Safety, where current matters are raised and discussed. Where necessary, the Health and Safety Manager can ask to attend these sessions to discuss specific topics or concerns. Likewise, the manager at any of those meetings can also request the Health and Safety Manager’s attendance for similar reasons.

Management Briefings NSL’s Executive Board is briefed on a monthly basis on safety developments, safety performance, and other issues by the Health and Safety Manager. Cascading Instructions New or revised safety information /procedures are provided by amendments or additions to the Health and Safety Manual and distributed through Operations Meetings, the SafetyNet communications network and are uploaded to the NSL intranet (CASCADE), and can be supplemented by person to person briefings or training if necessary.

CASCADE All health and safety information, policies, procedures and documentation is available at all times electronically on the NSL intranet – CASCADE.

SafetyNet A communications network that allows Safety Representatives and Safety Co-ordinators from across all NSL locations to communicate with each other via email / forum has been implemented. At least one individual from every contract has access to SafetyNet and can use it to ask questions, share best practice and offer suggestions.

7.0 Planning health and safety

7.1 Setting Standards Written standards for health and safety are set with the objective of achieving required standards of safety and to control risks. Standards also give managers the facility to monitor and measure performance. The standards are based on best practice within industry generally or NSL specifically. They are laid down, for example, in the Health and Safety Manual and the Colleague Health and Safety Handbook which are based on recognised sources such as HSE guidelines, Codes of Practice and national standards.

7.2 Risk Assessments Risk Assessments are completed and recorded in accordance with the Management of Health and Safety at Work Regulations and are circulated for the attention of all persons involved. It is the responsibility of all employees to report hazards to enable a speedy assessment to be made.

Risk assessments are carried out for all activities and workplaces by the Contract Manager and full details are recorded. These are cascaded through the all departments, as required, to ensure that all hazards are eliminated or controlled.

Contract Managers also carry out risk assessments as required when contractors report to premises to carry out works. Following discussion with the contractor on all health & safety matters relating to the works, the hazards are assessed as they relate to that particular workplace and the risks involved to staff or visitors. Particular attention is paid to materials and equipment in use and the processes required to conduct the work. Direct contact can then be made with the Health and Safety Manager if advice in controlling any hazard is required.

7.3 Safe Systems of Work It is NSL policy that hazards in the workplace are identified, assessed and either eliminated or controlled. Safe systems of work for routine hazardous activities are prepared by the managers, supported by the Health and Safety Manager if necessary, and issued as written instructions, to the staff whom they affect and who may then receive any necessary instruction and training. Safe systems of work are monitored and enforced by all managers. Employees who do not reach the required standards are retrained until they do. Employees who do not carry out safe systems of work or comply with safety instructions are subject to the company’s disciplinary procedure. All safety procedures are reviewed by Contract Managers, with advice as necessary from the Health and Safety Manager. All non-routine activities are assessed by Contract Managers before work starts and employees are advised of any hazards which cannot be eliminated. All necessary instruction and training is given before work commences.

7.4 Inspections and Audits Contract Managers carry out formal safety inspections of areas under their control regularly in order to identify and eliminate hazards in the workplace. Basic checks are carried out daily, with more detailed monthly inspections required. Quarterly and annual inspections are also submitted to the Health and Safety Manager once complete.

The Health and Safety Manager / Professional Standards Controller carry out safety audits of NSL workplaces to monitor the implementation of the Health and Safety Policy, Safety Standards, Systems of Work and Safety Management systems covering all principal areas. The safety audits are issued to the senior manager concerned who are required to respond to all the issues raised in the reports. The implementation of safety audit recommendations are, monitored by the Health and Safety Manager.

7.5 Purchasing Before purchasing any plant or equipment a risk assessment is made of any possible hazards. Only plant or equipment which conform to European standards and display the CE mark are purchased or used.

8.0 Implementing health and safety

8.1 Access to Work forms. Prior to commencement of any works on NSL premises, two copies of an Access to Work form and any applicable risk assessments must be completed by the person initiating the works order. Copies of these documents must then be sent to both the Contractor appointed and the Manager responsible for the premises concerned.

The Access to Work form is issued for all works on NSL premises, in order to provide operations staff with written evidence that contractors have been given permission to access the property concerned, to carry out the required works. The Contractor is responsible for issuing a copy of the Access to Work form to his staff members allocated to that job. Failure by any Contractor or his appointed staff representative, to produce a copy of this Access to Work form upon request from any employee of NSL, may result in access to the premises concerned being refused.

Access to Work forms and any applicable Risk Assessments, are also issued to the manager of the premises concerned, by the initiating manager for all new works (not routine maintenance).

8.2 Chemical safety NSL carries out assessments of all hazardous substances used by employees and ensures that adequate control and monitoring measures are carried out. Information and training are also given to employees to ensure that they handle hazardous substances safely as required by the Control of Substances Hazardous to Health Regulations. Assessments of all new substances are carried out by the Health and Safety Manager based on information contained within the Material Safety Data Sheets before purchase and before their use in the workplace. In accordance with the procedures for controlling hazardous substances, management and staff are advised of any control measures needed. Where appropriate, the use of safer, alternative products is recommended. Contractors are required to provide details of any hazardous substances, which they propose to use before starting work on NSL premises.

Chemical and other hazardous substance procedures are described in more detail in Section 19 of the Health and Safety Manual.

8.3 Personal protective equipment (PPE) The use of personal protective clothing is authorised by the Health and Safety Manager and is provided free of charge to those required to wear it. All protective clothing must conform to EU Standards and display the CE mark, and through quality and design must be fit for its intended purpose. Employees must take care of their protective clothing and keep it in a clean and serviceable condition. Managers carry out regular checks of protective clothing and protective equipment. Arrangements for personal protective equipment are described in more detail in Section 16 of the Health and Safety Manual.

8.4 Electrical Safety NSL has procedures regarding electrical safety that ensure that employees and others are not placed at any undue risk. Portable electrical appliances are visually inspected on a quarterly basis to confirm that they are still in good condition, and formal inspections are also undertaken. Residual current devices (RCD) are used to further protect the user of electrical equipment.

Fixed electrical circuits and installations in premises are inspected to maintain safety by competent specialists.

Responsibility for ensuring safe working with electrical equipment rests with the Contract Manager and only fully trained and qualified employees are permitted to undertake electrical work.

8.5 Manual Handling Assessments of the risks to the health and safety of employees resulting from the handling of loads are made by line managers. Written recommendations are made by the Health and Safety Manager for action to reduce or eliminate the risk of injury. Where practicable, equipment is designed to reduce manual handling risks and loads are reduced in size to make them manageable. Managers and the Learning and Development Dept instruct staff in manual handling techniques and give regular refresher training in accordance with current guidance.

9.0 Health and safety information

Employees are given information during their induction on hazards that may be encountered during the course of their duties. Information and advice on health and safety matters is available from the Health and Safety Manager on health, safety and fire safety, including legislation, HSE guidelines, Codes of Practice etc. Management and employees are kept informed of developments and new health and safety legislation, outlining the details as they affect employees, by means of training and the many communication and consultation methods. The sources of health and safety information available to employees on site are listed in Appendix E. 10.0 Training and competence

Safety training is provided and covers employees' basic responsibilities under the Health and Safety at Work etc Act 1974 and the procedures and duties relevant to their own workplace. Induction training is provided for all recruits and staff upon promotion and additional training is completed that is specific to each site/job role.

The health and safety training needs of all categories of employee are constantly under review by the Health and Safety Manager and the Learning and Development Dept to ensure that employees are fully competent to carry out work safely. Risk assessment identifies specific training requirements for particular job roles, and this training is delivered either in-house or by an external training provider in the case of specialist applications.

11.0 Safety of members of the public

The safety of customers and other members of the public on NSL premises is given the highest priority. Public areas are regularly inspected so that hazards or allurements (especially for children) can be eliminated or reduced. The following are examples of safety controls employed by NSL to promote and maintain a safe environment in the public areas:-

- Regular cleaning and maintenance of lighting, floors, etc.
- Clear signing of any hazards and evacuation routes.
- Alarm systems.
- Staff trained to direct and reassure members of the public during emergencies.
- Control of contractors to ensure that their activities do not endanger the health and safety of members of the public.
- Immediate investigation of accidents to members of the public to prevent any possible recurrence of similar accidents.

11.1 Disabled Persons

NSL endeavours to ensure all disabled members of the public using the services provided, have suitable access and egress to and from those services. Access surveys of NSL premises are completed and where necessary NSL make reasonable alterations to their premises in order to ensure such access is available. If further action is required in due course, NSL will review the current arrangements on a site by site basis as required, to decide if any further reasonable improvements are necessary.

12.0 Contractors

A contractor can be defined as anyone who works for the company but is not an employee. NSL requires all contractors selected from its approved list of contractors to demonstrate their commitment to safe working by providing a copy of their safety policy. Contractors are issued with the "Contractors Guidance Notes and Safety Rules" with which they must comply, and their employees receive information on procedures such as local emergency procedures and risk assessments, when they attend specific workplaces. All contract documentation requires the contractor to adopt the safety standards and systems of work described in the “Contractor Guidance Note and Safety Rules” which is included in the Health and Safety Manual.

Contractors are required to maintain compliance with Control of Asbestos Regulations 2006 where there is any possibility that they may have any contact with or work in the vicinity of asbestos. This is described in more detail in Section 11 of the Health and Safety Manual.

13.0 Emergency procedures

13.1 Pre-planning In consultation with the emergency services and operational management, written emergency procedures are prepared by the Health and Safety Manager for foreseeable major incidents such as fire, explosion or other emergency. These procedures are reviewed regularly and updated when changes are necessary and employees are trained in their roles during an emergency.

Emergency procedures are tested regularly by practice drills and training is given in accordance with risk assessments to provide maximum readiness. Any emergency equipment that has been identified as required is provided at appropriate places and regularly inspected to maintain its effectiveness.

13.2 Fire All sites have a specific Fire Risk Assessment, which is prepared locally with assistance where required from the Health and Safety Manager. Full details on Fire procedures are described in Section 13 of the Health and Safety Manual, including prevention, personnel and emergency action.

13.3 First Aid Initial emergency treatment for minor injuries and illness is provided with first aid kits being available in all working areas. Where identified as required by a risk assessment, sufficient personnel are designated as First Aiders, and receive accredited training (and subsequent refresher training). Notices informing employees how and where to access first aid treatment and including the names of all First Aiders are displayed around each workplace.

14.0 Occupational health

The Health and Safety Manager advises managers and staff on occupational health matters and provides a contact point with health professionals. External occupational health professionals advise the company and referrals are arranged through contract management.

14.1 Smoking NSL recognises the harmful effects of smoking in the work place and aims to protect non-smokers at work from the harmful effects of passive smoking. It also aims to assist smokers to give up the habit and can arrange counselling where appropriate.

14.2 Alcohol and drugs NSL restricts the consumption of alcohol at work and prohibits the keeping or using of drugs (except those issued for a specific medical condition) on company premises. Counselling and advice will be made available to staff with alcohol or drug problems. 14.3 New and expectant mothers NSL has a comprehensive policy / procedure relating to new and expectant mothers based on the Management of Health and Safety at Work Regulations, which are available in the Health and Safety Manual, Section 25. An assessment is completed to identify any risks to the health, safety and welfare at work of any new or expectant mothers, who are defined as;

- Expectant Mother - a woman who has supplied a medical certificate (or similar) stating she is pregnant.
- An employee who has recently given birth - an employee during the 6 months immediately after giving birth (even if this was a miscarriage or stillbirth).
- An employee who is breastfeeding - an employee who is breastfeeding during the period after giving birth.

14.4 Health surveillance The requirement for ongoing health surveillance is not currently assessed as required by NSL employees, however regular health assessments are offered to employees who work at night.

15.0 Measuring performance

15.1 Monitoring NSL constantly monitors the safety performance of all contract locations both pro-actively and reactively, including the use of routine checks, which are carried out by managers and other supervisory staff. The following formal methods are also used:-

- Random safety audits conducted by the Health and Safety Manager.
- Continuing risk assessments and reviews.
- Accident / incident investigations.
- Maintenance and review of records and statistics.
- Regular self assessment health and safety inspections undertaken by local managers.
- Formal Continuous Improvement audits undertaken by the Professional Standards Controller.

15.2 Incident investigation All accidents and dangerous occurrences are investigated to ensure that steps are taken, where reasonably practicable, to prevent a recurrence. Accidents and dangerous occurrences are initially investigated by the contract management in accordance with Section 8 of the Health and Safety Manual. They are also reported, where required, to the Health and Safety Executive in accordance with the Reporting of Injuries, Diseases and Dangerous Occurrence Regulations 1995.

Accidents involving other company’s employees or members of the public are also recorded and investigated. For all serious or potentially serious accidents, an Investigating Team may be set up and a report prepared by them, with conclusions and recommendations for implementation.

15.3 Accident Records and Statistics Copies of all incident reports are held for three years. Key information is extracted from the reports and kept on a statistical data record, identifying accidents to employees and members of the public and categorising them into the type of accident and the nature of any injury. Statistics showing accident trends are routinely extracted and issued to management by the Health and Safety Manager. 15.4 Targets Health and safety targets relating to specific types of accidents are introduced, when required, to reduce accidents in that category. Objectives are set by the Health and Safety Manager, approved by the NSL Executive Board and cascaded as targets through the company.

16.0 Review Safety standards and performance are regularly reviewed with the aim of making continual improvements to safety systems and practice. The NSL Executive Board receives a review of NSL safety objectives and performance on a regular basis.

Review systems include:-

- Evaluation of recommendations from audits, surveys and accident/incident investigations.
- Annual review of safety performance.
- Evaluation of accident statistical data.
- Continual development of strategies, targets and action plans.

The NSL Safety Statement and Chief Executive’s Health and Safety Policy Statement are reviewed at least annually and any updates brought to the attention of all employees without delay. Reviews take place sooner than this if significant changes in the organisation, personnel or operations occur. APPENDIX A

DUTIES OF MANAGERS

Managers are responsible for ensuring the health and safety of their staff at work, or others who may be affected, together with the safety of the premises and equipment they control. Accordingly they are required to:-

- Carry out safety inspections of the workplace, plant and equipment including regular checks for good housekeeping.

- Check that all equipment and plant for use at work is safe and adequately maintained.

- Ensure that adequate facilities for welfare exist in the workplace.

- Carry out risk assessments to ensure safe systems of work for any potentially hazardous work activity, including work carried out by contractors. The system of work, together with precautions to be taken, must be written on a standard Risk Assessment form and enforced.

- Ensure that contractors employed to carry out work at sites under their control, work safely and are not a danger to the health and safety of employees or members of the public.

- Confirm with contractors they have seen a copy of the Contractors Guidance Notes and Safety Rules and discuss the health & safety implications of the work, checking or completing any risk assessment and access to work form as required.

- Ensure that all employees receive information and training in order that they may carry out work safely and without risks to health.

- Investigate accidents and dangerous occurrences to prevent any recurrence and ensure completion of company and statutory accident reporting forms.

- Maintain statutory health and safety records and adequate records of other health and safety activities (e.g. training and inspections).

- Consult with employees on safety matters.

- Consult with the Health and Safety Manager on proposals for new installations or alterations to the work place.

- Ensure that employees know what to do in the event of an accident, fire or other serious occurrence.

- Ensure that articles and substances can be transported, handled, used and stored without risks to safety or health.

- Ensure that employees follow safety rules and instructions and, where necessary, enforce them.

- Ensure the issue of protective clothing or equipment where required and provide training in its correct use and maintenance. APPENDIX B

DUTIES OF EMPLOYEES

The Health and Safety at Work etc Act 1974 and NSL policies require employees to;

- Comply with the relevant statutory provisions, as appropriate, and take reasonable care to protect his or her safety, health and welfare and the safety, health and welfare of any other person who may be affected by the employee’s acts or omissions at work

- Ensure that he or she is not under the influence of an intoxicant to the extent that he or she is in such a state as to endanger his or her own safety, health or welfare at work or that of any other person

- Co-operate with management or any other person so far as is necessary to enable NSL to comply with the relevant statutory provisions, as appropriate

- Not engage in improper conduct or other behaviour that is likely to endanger his or her own safety, health and welfare at work or that of any other person

- Attend such training and, as appropriate, undergo such assessment as may reasonably be required by NSL relating to safety, health and welfare at work or relating to the work carried out by the employee

- Having regard to his or her training and the instructions given by NSL, make correct use of any article or substance provided for use by the employee at work or for the protection of his or her safety, health and welfare at work, including protective clothing or equipment

Employees must also report to his or her line manager or to any other appropriate person, as soon as practicable;

- Any work being carried on, or likely to be carried on, in a manner which may endanger the safety, health or welfare at work of the employee or that of any other person

- Any defect in the place of work, the systems of work, any article or substance which might endanger the safety, health or welfare at work of the employee or of any other person

- Any contravention of the relevant statutory provisions which may endanger the safety, health and welfare at work of the employee or that of any other person, of which he or she is aware.

Employees are informed of their duties under the Health and Safety at Work etc Act 1974 during induction and other safety training courses and the relevant sections of the Act are summarised in the Colleague Health and Safety Handbook, for the information of all staff. APPENDIX C

DUTIES OF THE HEALTH AND SAFETY MANAGER

The Health and Safety Manager is responsible for ensuring compliance with the Company Health and Safety Policy and current safety legislation and that the highest standards of safety, health and welfare are maintained through the following activities:-

- Carrying out safety audits and inspections of workplaces and public areas to ensure safety standards are maintained and reported
- Identifying safety training requirements and appropriate training programmes for all levels of employee
- Advising on health and safety legislation and best practice
- Maintaining records of accidents to employees and members of the public
- Analysing accident statistics to identify trends and recommending appropriate action, investigating any serious accidents and dangerous occurrences and making recommendations to management to prevent a recurrence
- Carrying out surveys and risk assessments of premises to ensure the highest standards of health and safety are maintained
- Liaising with Inspectors of the Health and Safety Executive to ensure high overall health and safety standards
- Keeping up to date with developments health and safety best practice through courses, seminars and literature
- Ensuring that manual handling, visual display unit (VDU) and pregnant employee assessments are conducted where required by suitably competent persons
- Maintaining good communications and consult regularly with Directors, Senior Managers and employees, seeking assistance and actions to resolve outstanding issues
- Attending Health and Safety Committee meetings, and ensuring compliance with company procedures at all levels
- Reviewing plans for new or modified facilities and advising on any safety matters that need attention
- Attending pre-implementation meetings to advise project teams on health and safety matters from the design stage, through to completion
- Maintaining the Approved Contractors List and ensure that all assessments of competence / health and safety policies are retained. APPENDIX D

HEALTH AND SAFETY TRAINING

Examples of health and safety training provided for employees are set out below:-

Senior Managers Senior managers get an annual update which covers their responsibilities for health and safety, and any changes in legislation, policy etc.

Managers Managers attend a one day course covering their health and safety responsibilities and how to manage safety. This training is carried out by the in-house Learning and Development Department. The content of the courses is based on current legislation and includes subjects such as risk assessment, incident reporting and investigation, premises, vehicles and work equipment.

Team Leaders Team Leaders receive a half-day course covering their health and safety duties and their responsibilities to themselves, their teams and to NSL, which are carried out by the in-house Learning and Development Department.

Other Employees Other employees receive health and safety training which covers their responsibilities under the Health and Safety at Work etc Act 1974 and the actions they can take to maintain high safety standards in their workplaces. On-the-job training in the health and safety aspects of their work is provided by their managers on starting new work or through refresher training.

Induction Training Health and safety sessions are included in the programme for all employee induction training courses.

Specialist safety training for hazardous work Specialist training for employees who work in hazardous areas, with hazardous equipment or on hazardous activities, is provided by in-house specialists or external trainers.

Training for fire and other emergencies Training for all employees in fire prevention and emergency evacuation is provided in accordance with the relevant fire risk assessment and managers are given training in the control of emergencies during their Health and Safety training course. Practical training in the use of fire fighting equipment is carried out where identified as being necessary by specialist instructors.

Health and Safety Manager The Health and Safety Manager attends continuing professional development courses and seminars to keep abreast of developments in the field of health and safety.

First Aid Training Volunteers train to become fully qualified first aiders and also attend First Aid refresher training and CE marked first aid kits are available at every place of work. APPENDIX E

HEALTH & SAFETY INFORMATION

All employees are issued with a copy of the Colleague Health and Safety Handbook which requires a signature to confirm receipt. Managers are responsible for the issue and control of the Colleague Health and Safety Handbook.

All Contract locations have copies of the following:-

01. The Company Health and Safety Manual.
02. The Company Health and Safety Policy Statement.
03. The NSL Safety Statement
04. Safe systems of work / operating procedures
05. Applicable Hazard Data Sheets.
06. Relevant risk assessments.
07. Asbestos assessment and management information.
08. Emergency procedures.
09. Safety Circular - Consultation with Employees.
10. Employee Response Sheets.
11. Contractors’ Guidance Notes and Safety Rules.
12. Maintenance / Test Log sheets.
13. Contract Managers have electronic access to the NSL Health & Safety Manual”.

The following information is available from the Health and Safety Manager:-

Copies of all legislation, Guidance Notes, Data Sheets, Assessments, Inspection Records and internal safety instructions.